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COMCAST CORP. & SUBSIDIARIES v. DOR

(TC 5265) (SC S064698).

423 P.3d 706 (2018)

363 Or. 537

COMCAST CORPORATION AND SUBSIDIARIES, Plaintiff-Appellant, v. DEPARTMENT OF REVENUE, Defendant-Respondent.

Supreme Court of Oregon, En Banc.

August 16, 2018.

Attorney(s) appearing for the Case

Timothy A. Gustafson , Eversheds Sutherland (US) LLP, Sacramento, California, argued the cause for appellant. Gregory A. Chaimov and Mark P. Trinchero , Davis Wright Tremaine LLP, Portland, filed the briefs for the appellant. Also on the briefs were Timothy A. Gustafson , Eversheds Sutherland (US) LLP, Sacramento, California, and Jeffrey A. Friedman , Eversheds Sutherland (US) LLP, Washington, District of Columbia.

Marilyn J. Harbur , Assistant Attorney General, Salem, argued the cause and filed the brief for respondent. Also on the brief were Ellen F. Rosenblum , Attorney General, and Benjamin Gutman , Solicitor General.

In this appeal from a decision of the Oregon Tax Court, taxpayer challenges the Tax Court's construction of the statutory formula by which Oregon calculates the portion of an interstate broadcaster's income that is taxable by Oregon. See ORS 314.680 to 314.690.1 Based in part on those statutes, the Oregon...

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